Draft DC On Testing and Commissioning - PubCon (Karen)

Draft Department Circular
Adopting a General Framework

Governing the Test and
Commissioning of Generation
Facilities
Public Consultation – Luzon Leg
29 June 2020
Department of Energy
Empowering the Filipinos
Presentation Outline
Background Overview of Summary of

Draft Department Received
Circular Comments
Background
Background
❖ Article I, Section 2 (iii) of the 2014 Revised Rules for the Issuance of
Certificates of Compliance (COCs) for Generation Companies and Entities
with Generation Facilities - Maximum period of two (2) months for the
conduct of Test and Commissioning for new Generation Facilities
❖ Several plants were recorded to have exceeded the two-month Test and
Commissioning period with thirty-nine (39) plants on prolonged Test -- the
longest period being 1829 days, as of 08 January 2020*
❖ The extended Test and Commissioning of generating facilities pose material

effect to WESM outcomes by displacing scheduled generators while not
being required to comply with requirements for submission of offers or
projected outputs;
Background
❖ Focus Group Discussions (FGDs) conducted in 2019
Leg Date Venue

Luzon 11 November 2019 Metro Manila
Visayas 14 November 2019 Cebu City
Mindanao 19 November 2019 General Santos City
Overview of Draft
Department Circular
Overview of Draft Department Circular
Guiding Principles:
❖ No Generation Company and its Generating Unit/s shall

commercially operate and participate in the WESM unless it has
secured a Certificate of Compliance from the ERC;
❖ No other certification, aside from the COC, shall qualify as license to

operate under commercial operations;
❖ All Generation Company/ies intending to conduct Test and

Commissioning of their Generating Units shall comply with the
requirements provided under this Circular and the applicable ERC
guidelines for the issuance of the COC; and
❖ The conduct of Test and Commissioning shall not adversely affect the
security and reliability of grid operations as well as the
competitiveness of market outcomes.
Scope and Application
✓ Generation Companies operating or intending to operate Generation

Facilities
✓ Grid-Connected
✓ Embedded
✓ System Operator (SO)
✓ Market Operator (MO)
✓ Network Service Providers (NSPs)
✓ Transmission Network Provider (TNP)
✓ Distribution Utilities (DUs)
× Self-Generating Facilities
Definition of Terms
❖ “Commercial Operations” refer to the generation of electricity for sale or
disposition of a Generation Facility with a valid COC issued by the ERC.
❖ “Electromechanical Completion” shall mean that the generating unit

including all substation and other facilities for grid or distribution system
connections are in place and fully commissioned in accordance with owner
and manufacturer specifications.
❖ “Provisional Authority to Operate” or “PAO” refers to the certification

issued by the ERC, with a specific date of validity, to a Generation Company,
allowing the conduct of Test and Commissioning with respect to its
Generation Facility/ies.
❖ “Test and Commissioning” refers to conduct of set of procedures to show

that a generating unit was erected and connected in accordance with the
Philippine Grid Code, Philippine Distribution Code and other relevant
guidelines and specifications and to determine readiness to deliver energy to
Grid or distribution network.
Procedures for before, during and after Test and Commissioning
Black – Applicable to all GenCos

Green – Applicable to GenCo applying for FIT eligibility
Genco
achieves Genco IEMOP
electro- applies for approves
Start of plant mechanical COC from WESM
construction completion ERC registration
1 2 3 4 5 6 7 8 9
1 2 3 4 5 6 7 8
Genco DOE Genco NGCP

applies validates applies with approves
for COE electro- IEMOP and connection
from DOE mechanical NGCP for to the Grid
completion backfeed
and provides power
endorsemen provision
t for ERC,
NGCP and
IEMOP

ERC
issues IEMOP updates
Start of DOE PAO for registration
Internal Test issues conduct status of Genco
and COE to of Grid to Test and
Commissioning Genco T&C Commissioning
9 10 11 12 13 14 15 16
End of Internal Genco Genco Genco

Test and applies provides provides
Commissioning for PAO PAO to PAO to
to IEMOP NGCP
conduct
Grid T&C
from ERC
Scenario 1: The plant completed the Grid T&C activities within the
prescribed period Black – Applicable to all GenCos
NGCP Green – Applicable to GenCo applying for FIT eligibility
provides NGCP issues Final
schedule* of Approval to
Grid T&C to Connect and results
GenCo and End of of Grid T&C to the Genco Genco
informs the prescribed Genco and informs completes all provides
same to ERC period the same to the COC COC to
and IEMOP ERC requirements IEMOP
17 18 19 20 21 22 23 24 25 26
2
months IEMOP Genco ERC issues IEMOP
discontinues submits Final COC to updates
Start of payment to Approval to Genco and Genco
Grid GenCo for plant Connect and informs registration
T&C injections + results of Grid the same to full
NGCP T&C to ERC to IEMOP commercial
discontinues and DOE operation
submission of
security limits**
*GenCo should notify NGCP of schedule of Grid T&C six (6) months prior the conduct thereof
** May be skipped if Step 25 is completed before the end of the Grid T&C prescribed period
Scenario 2: The plant was unable to comply Grid T&C activities within the
prescribed period Black – Applicable to all GenCos
provides
schedule* of NGCP issues
Grid T&C to results of T&C
GenCo and to GenCo and Genco
informs the End of informs the addresses
same to ERC prescribed same to ERC T&C
and IEMOP period and DOE issues
17 18 19 20 21 22 23 24
IEMOP
Start of GenCo
discontinues Go to
Grid T&C notifies
payment to
DOE of
GenCo for plant 9
results of
injections + NGCP
T&C
discontinues
submission of
security limits

ERC
issues IEMOP updates
Start of DOE PAO for registration
Internal Test issues conduct status of Genco
and COE to of Grid to Test and
Commissioning Genco T&C Commissioning
9 10 11 12 13 14 15 16
End of Internal Genco Genco Genco

Test and applies provides provides
Commissioning for PAO PAO to PAO to
to IEMOP NGCP
conduct
Grid T&C
from ERC

schedule of Approval to
GenCo and of Grid T&C to the Genco Genco
informs the End of Genco and informs completes all provides
same to ERC prescribed the same to the COC COC to
and IEMOP period ERC requirements IEMOP
17 18 19 20 21 22 23 24 25 26
Start of IEMOP Genco ERC issues IEMOP

Grid discontinues submits Final COC to updates
T&C payment to Approval to Genco and Genco
GenCo for plant Connect and informs registration
injections + results of Grid the same to full
submission of
security limits**
Scenario 3: With extension of PAO (with valid grounds of extension*)
IEMOP
NGCP discontinues
provides Genco payment to Genco
schedule* of applies GenCo for plant provides
Grid T&C to for injections + extended
GenCo and extension NGCP PAO to
informs the of T&C discontinues IEMOP
same to ERC with the submission of and
and IEMOP ERC security limits** NGCP
17 18 19 20 21 22 23 24
Start of End of ERC Go to

Grid T&C prescribed issues
period extension 17
of PAO

schedule of Approval to
GenCo and of Grid T&C to the Genco Genco
informs the End of Genco and informs completes all provides
same to ERC prescribed the same to the COC COC to
and IEMOP period ERC requirements IEMOP
17 18 19 20 21 22 23 24 25 26
1
month IEMOP Genco ERC issues IEMOP
Start of discontinues submits Final COC to updates
Grid payment to Approval to Genco and Genco
T&C GenCo for plant Connect and informs registration
injections + results of Grid the same to full
submission of
security limits**
Grounds for extension of Test and Commissioning
✓ Resource limitation of VRE facilities such as solar and wind energy

unavailability due to weather conditions and water availability issues
✓ Threat to system security exists due to grid conditions such as alert
or emergency state and/or transmission line congestion or limitation
✓ Force majeure events
× Technical issues internal to the Generating Facility
Responsibilities of various entities
System Operator
❖ Ensure reliability of Grid Operations during Test and Commissioning
of Generation Facilities
❖ Implement real time security dispatch in an event of an abnormal

system condition
❖ Notify the DOE,ERC and the Generation Company concerned of

instances when Test and Commissioning has adverse impacts to
Grid operations
❖ Report to the DOE, ERC and the Generation Company concerned

when the Test and Commissioning is extended due to an event in the
Grid
Transmission Network Provider
❖ Ensure that the Generation Facility/ies has attained Electromechanical Completion prior to
the conduct of Test and Commissioning
❖ Ensure timely conduct of Test and Commissioning procedures of Generation Facilities
❖ In coordination with Generation Companies and other relevant stakeholders, shall develop
Test and Commissioning Guidelines for Grid connected Generation Facilities
❖ In coordination with Distribution Utilities, develop Test and Commissioning Guidelines for
Embedded Generators
❖ Submit the said procedures to the DOE and ERC for approval, within sixty (60) days from
the effectivity of this Circular; and
❖ Ensure adherence to the Maximum Allowable Period for Test and Commissioning and report
to the DOE and ERC any instances of violation by Generation Facilities
Market Operator
❖ Prepare and submit to the Rules Change Committee proposed
changes to the WESM Rules and relevant Market Manuals in
accordance with the policy provided herein as necessary
❖ Ensure timely processing of applications for registration of

Generation Companies undergoing Test and Commissioning
❖ Ensure timely updating of the Market Network Model and close

coordination with the System Operator
❖ Ensure adherence to the maximum allowable period for Test and

Commissioning and report to the DOE and ERC any instances of
violation by Generation Facilities
Regulatory Support
❖ Review, update and harmonize with the DOE MO, SO and the TNP, as
necessary, all pertinent resolutions and regulations relevant to the
implementation of the policies stated under this Circular and promulgate
guidelines on the same
❖ Closely monitor and maintain an updated recordkeeping of inventory of

Generation Facilities undergoing Test and Commissioning
❖ Ensure timely issuance of PAO and COC, consistent with the timelines
provided in this Circular
❖ Implement enforcement and penalty mechanisms in cases of non-

compliance with this Circular by any Electric Power Industry Participant
identified herein
Summary of Submitted
Comments
Summary of Submitted Comments
Comments DOE Response
Provisional Authority to Operate has a As discussed with ERC, retain PAO as
different purpose in the COC Rules provisional document for commercial
operations and consider another
certificate to be issued for Grid T&C
Consistency with the COC Rules Final draft will be consulted with ERC
Sufficiency and scope of 2-month T&C period will only cover T&C activities
prescribed period for Test and upon synchronization with the Grid,
Commissioning specifically the conduct of Generating
Capability and Grid Compliance Tests
Per NGCP, 2 months is sufficient to

complete these tests assuming no
internal issues encountered within the
plant. Inclusion of technical issues as a
ground for extension is being considered.
Lack of definite timelines between each Discussions were made with ERC, NGCP
procedure and IEMOP to reflect respective current
processing timelines
Objection to disconnection in the event Considered for amendment and will be
of Test and Commissioning exceeding the harmonized with the revised
prescribed period Disconnection policy
Need for transitory provisions for those To be considered in final draft
plants currently undergoing Test and
Commissioning
Feasibility of requiring electromechanical Already revised the procedures –
completion prior to COC application electromechanical completion required
prior to Grid T&C instead
Rationale behind the 6-month notice for Per NGCP, 6 months is ideal to ensure
scheduling of the Grid Test and proper scheduling of generator requests
Commissioning
Consider plants on Test and Per NGCP, this will compromise Grid
Commissioning as additional supply reliability as plants on test and
during deficiencies commissioning have potential to go on
outage during conduct of tests
Applicability of provisions to Embedded EGs with material impact to the Grid (as
Generators defined in DC2019-12-0003) should be
subject to Grid T&C. For harmonization
with T&C activities with DU
Delay in Test and Commissioning due to Per NGCP, for Grid T&C, no permits from
permits needed from other agencies other agencies are being required
Recommendation to require posting of For consideration and further discussion
prudential requirements during backfeed
operations and test and commissioning
Impact of non-payment of injection for For further discussion with IEMOP
those on extended T&C to Net
Settlement Surplus
End of Presentation
Thank You!
(+632)
(+632) 479-2900 loc 264
8479-2900
pmdd.wesm@gmail.com
name@doe.gov.ph
www.doe.gov.ph
www.doe.gov.ph
https://web.facebook.com/doe.gov.ph
//doe.gov.ph
@doe_ph
@doe_ph

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Draft Department Circular

Adopting a General Framework

Background Overview of Summary of

❖ The extended Test and Commissioning of generating facilities pose material

❖ Focus Group Discussions (FGDs) conducted in 2019

Leg Date Venue

Mindanao 19 November 2019 General Santos City

❖ No Generation Company and its Generating Unit/s shall

❖ No other certification, aside from the COC, shall qualify as license to

❖ All Generation Company/ies intending to conduct Test and

Scope and Application

✓ Generation Companies operating or intending to operate Generation

❖ “Electromechanical Completion” shall mean that the generating unit

❖ “Provisional Authority to Operate” or “PAO” refers to the certification

❖ “Test and Commissioning” refers to conduct of set of procedures to show

Black – Applicable to all GenCos

Genco DOE Genco NGCP

Black – Applicable to all GenCos

End of Internal Genco Genco Genco

Black – Applicable to all GenCos

End of Internal Genco Genco Genco

Black – Applicable to all GenCos

Start of IEMOP Genco ERC issues IEMOP

Start of End of ERC Go to

Black – Applicable to all GenCos

Grounds for extension of Test and Commissioning

✓ Resource limitation of VRE facilities such as solar and wind energy

× Technical issues internal to the Generating Facility

Responsibilities of various entities

❖ Implement real time security dispatch in an event of an abnormal

❖ Notify the DOE,ERC and the Generation Company concerned of

❖ Report to the DOE, ERC and the Generation Company concerned

❖ Ensure timely conduct of Test and Commissioning procedures of Generation Facilities

❖ Ensure timely processing of applications for registration of

❖ Ensure timely updating of the Market Network Model and close

❖ Ensure adherence to the maximum allowable period for Test and

❖ Closely monitor and maintain an updated recordkeeping of inventory of

❖ Implement enforcement and penalty mechanisms in cases of non-

Per NGCP, 2 months is sufficient to

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